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Respondent accepted petitioner’s amended return and abated
petitioner’s tax accordingly.
C. Final Notice Of Intent To Levy
On January 21, 2003, respondent sent petitioner a Final
Notice Of Intent To Levy And Notice Of Your Right To A Hearing
with respect to petitioner’s outstanding tax liabilities for 1999
and 2001. See sec. 6330(a).
On February 19, 2003, petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing (CDP hearing). On
the Form 12153, petitioner stated:
The IRS filed a Notice of Levy on 01/21/03, and
actually mailed it on 01/31/03. In the interim, I
requested for more time to file amended returns for
1999, 2000 & 2001 because of errors.[3]
On April 2, 2003, respondent’s collection office forwarded
the Form 12153 to respondent’s Appeals Office. The Appeals
Office received the case on April 7, 2003, and assigned the case
to Appeals Officer Michael M. McDonnell on June 26, 2003.
On July 24, 2003, the Appeals officer sent petitioner a
letter acknowledging that the Appeals Office had received
petitioner’s case and informing petitioner that the Appeals
officer would be “unable to work your case for 90 to 120 day
[sic].”
3 We note that only taxable years 1999 and 2001 are in
issue in the present case.
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